Classification conclusion
Handheld electric hair dryers enter under 8516.31.0000. Review the 3.9% base duty, origin-specific Chapter 99 duties and mandatory CPSC immersion protection.
| Field | Conclusion |
|---|---|
| Proposed HTS code | 8516310000 — Hair dryers |
| Jurisdiction | United States |
| Tariff edition | HTSUS 2026 |
| Rules applied | GIR/GRI 1 and 6 |
| Confidence | High when the entered merchandise matches the stated facts |
| Condition | A complete new handheld household electric hair dryer incorporating a fan motor and electric heating element, imported with its ordinary nozzles. |
U.S. HTSUS classification and duty at a glance
This guide covers a complete handheld electric hair dryer for household or personal grooming use, incorporating a fan motor and electric heating element and imported new with its ordinary nozzles.
| Product | HTSUS reporting number | Column 1 General | Column 2 |
|---|---|---|---|
| Electric hair dryer | 8516.31.0000 | 3.9% | 35% |
Vietnam's 8516.31.00 cannot simply be copied as a U.S. entry number. The U.S. ten-digit reporting number is 8516.31.0000.
Classification under the GRIs
GRI 1 places electrothermic hairdressing apparatus in heading 8516, whose text expressly includes hair dryers. GRI 6 selects subheading 8516.31, and the HTSUS completes the number as 8516.31.0000.
The product must use electricity to generate the heated airflow used to dry hair. CBP Headquarters Ruling HQ 959906 explains that a nonelectric butane-powered styling appliance was not electrothermic and therefore did not qualify as a hair dryer of 8516.31. That distinction reinforces the need to document power source and principal function.
Products outside the stated conclusion
- Curling irons, straighteners, heated brushes and other electrothermic hairdressing appliances generally fall in 8516.32.
- Electric hand dryers fall in 8516.33.
- Industrial heat guns used for plastics, paint or packaging are not hair dryers.
- Salon hoods, pet blowers, medical/therapeutic devices and multifunction appliances require a fact-specific analysis.
- Motors, heating elements, housings, cords or attachments imported separately are classified in their condition as entered.
Origin-specific duties and fees
The base Column 1 General duty is 3.9%. Preferential treatment may be available only where the product satisfies the applicable program's origin rules and entry requirements.
For China-origin hair dryers:
- The current legacy technology-transfer Section 301 dataset lists 8516.31.00 at 0% additional duty.
- The reviewed 2026 forced-labor Section 301 action adds 12.5% under 9903.05.31, absent a qualifying U.S. Note 52(b) exception.
- The combined duty is therefore ordinarily 16.4% before user fees when that 12.5% action applies.
For Vietnam-origin hair dryers, the same reviewed action currently adds 12.5% under 9903.05.84, absent an applicable exception, producing the same ordinary 16.4% combined rate before fees. Origin must be supported by manufacturing facts, not shipment or invoicing alone.
No Section 232 or Section 201 measure and no AD/CVD order specifically covering generic finished electric hair dryers were identified in the reviewed official datasets. Scope, producer, exporter and origin must still be searched close to entry. Formal entries are generally subject to the Merchandise Processing Fee at 0.3464%, within the applicable minimum and maximum; vessel cargo may also incur the 0.125% Harbor Maintenance Fee.
Mandatory CPSC immersion protection
Hand-supported household and commercial hair dryers must incorporate immersion protection complying with the referenced provisions of UL 859 or UL 1727. Under 16 CFR 1120.3(a), a hand-supported hair dryer lacking compliant integral immersion protection is deemed a substantial product hazard.
For a corded U.S. model, the compliance file should verify the integral protection circuit, typically reflected in an ALCI/IDCI-type test/reset plug or an approved protection design in the appliance. A GFCI-protected receptacle does not excuse a noncompliant dryer. CPSC has issued 2026 public warnings involving imported dryers that lacked this protection, so this is an active enforcement issue rather than a cosmetic certification point.
The importer should also retain model-specific electrical safety evidence addressing overheating, abnormal operation, accessible moving parts, cord anchorage, strain relief, flammability, thermal cutoffs, air-inlet blockage, markings and instructions. A recognized laboratory listing is commercially important and may be required by retailers or state/local electrical rules, but it does not replace the federal immersion-protection requirement.
Marking and entry documentation
- Datasheet and internal drawings showing fan motor, heating element, thermal protection, controls and airflow path.
- Rated voltage, frequency, wattage, heat/speed settings and supplied attachments.
- Test reports for UL 859 or UL 1727 as applicable, including immersion-protection and plug test/reset evidence.
- Country-of-origin determination and marking under 19 U.S.C. 1304 and 19 CFR part 134.
- Invoice description, model, producer, origin support and all applicable Chapter 99 lines.
- AD/CVD scope and UFLPA supply-chain review completed near entry.
Suggested commercial description
Handheld household electric hair dryer, incorporating fan motor and electric heating element, rated ... V, ... Hz, ... W, with integral immersion-protection test/reset plug, ... heat and speed settings, model ..., country of origin ..., HTSUS 8516.31.0000.
Replace every ellipsis with actual product data. Do not use this description for a hand dryer, heat gun, curling appliance or nonelectric styling product.
Official sources
- USITC current Harmonized Tariff Schedule
- CBP Headquarters Ruling HQ 959906
- CPSC hand-supported hair dryer guidance
- CPSC mandatory standards and bans
- USTR Section 301 investigations
- ITA ACCESS AD/CVD search
Conclusion
A complete handheld electric hair dryer is generally entered under HTSUS 8516.31.0000, with a 3.9% Column 1 General rate and 35% Column 2 rate. China or Vietnam origin currently requires a separate 12.5% Chapter 99 review under the 2026 action. Most importantly, a hand-supported dryer without compliant integral immersion protection is a substantial product hazard under 16 CFR 1120.3(a).
This publication is general information, not a binding CBP ruling or legal opinion. Final treatment depends on principal function, power source, construction, origin, producer and entry date.
Law and tariff reviewed through September 4, 2026.
2026 U.S. customs and import-law review
Legal review date: September 5, 2026. The USITC online HTSUS identified 2026 Revision 18 on this review date. Rates and Chapter 99 measures can change during the year, so the legally operative schedule is the edition in effect on the entry date.
1. Quick legal conclusion
The proposed reporting number is 8516310000 for Hair dryers, but only for merchandise that matches this defined scope: A complete new handheld household electric hair dryer incorporating a fan motor and electric heating element, imported with its ordinary nozzles. This is a fact-dependent classification opinion, not a CBP ruling and not a determination of admissibility, origin or AD/CVD scope.
2. Facts that must be verified before entry
- Principal function and intended household/personal use
- Voltage, frequency, wattage, motor, heater and thermal protection
- Origin, model, factory, attachments, reports and certification
Also obtain the complete bill of materials, technical drawings, model numbers, operating manual, condition and configuration as imported, transaction chain, manufacturer/producer, country of origin of material inputs and intended U.S. use. A material difference requires a new analysis.
3. HTSUS analysis and controlling authority
- GRI 1 places electrothermic hairdressing apparatus in heading 8516, whose text expressly includes hair dryers; GRI 6 selects 8516.31.
- The principal function must be producing heated airflow to dry hair, distinguishing the appliance from hand dryers, styling irons and industrial heat guns.
The analysis must begin with GRI 1, the heading text and binding Section/Chapter Notes, then proceed to GRI 2–5 only if legally necessary and to GRI 6 for subheadings. U.S. Additional Rules of Interpretation and Additional U.S. Notes are controlling where applicable. WCO Explanatory Notes are persuasive interpretive material but are not U.S. statutory text. A CROSS ruling is binding only for the requester and merchandise covered by its facts; materially similar rulings may be persuasive. CIT and Federal Circuit decisions control within their jurisdiction.
Goods outside this opinion include:
- Hand dryers, curling or straightening appliances, industrial heat guns, pet blowers and separately imported parts require separate classification.
For recurring or high-value entries, request a prospective binding ruling from CBP under 19 CFR Part 177 and disclose all material facts. A ruling request is not a substitute for checking post-ruling HTSUS amendments or trade remedies.
4. Duty, fee and tax matrix
| Charge | Legal treatment for this article |
|---|---|
| HTSUS Column 1 General duty | Apply the rate printed beside 8516310000 in the HTSUS edition effective on the entry date. Any rate stated elsewhere in the article remains provisional until that check is completed. |
| Merchandise Processing Fee (MPF) | Formal entries generally incur 0.3464% of entered value, excluding duty, freight and insurance, subject for FY 2026 to the CBP minimum $33.58 and maximum $651.50; an applicable preference program can alter MPF treatment. |
| Harbor Maintenance Fee (HMF) | 0.125% of value when commercial cargo is unloaded from a vessel at a covered U.S. port; it ordinarily does not apply to air freight. See 26 U.S.C. 4461–4462 and 19 CFR 24.24. |
| Section 301 / other Chapter 99 duty | Determine from the exact 8-digit HTSUS provision, country of origin, effective date and any valid exclusion. Report the required Chapter 99 number; do not assume the base HTS rate is the total landed duty. |
| Section 232 | Check current Chapter 99 notes, product/derivative coverage, origin and any required steel/aluminum/copper content, melt-and-pour or smelt-and-cast data. It does not apply merely because the article contains some metal. |
| AD duty | Not determinable from an HTS number. The written scope of an AD order is dispositive; HTS references are for convenience. Review product, producer/exporter, origin and circumvention findings. Cash-deposit and final assessment rates can differ. |
| CVD duty | The same written-scope rule applies. Confirm the case-specific company or all-others cash-deposit rate and liquidation instructions in Commerce ACCESS and ACE. |
| Safeguard / quota | Check current Chapter 99, quota and safeguard measures as of entry. Product scope, origin, quantity and quota period control. |
| Federal excise tax | No product-specific federal excise tax is identified from the stated facts; confirm the intended use and the current Internal Revenue Code before entry. |
| State sales/use and other state taxes | These are not CBP customs duties. They depend on destination, importer nexus, later sale/use and state/local law and require a separate domestic-tax review. |
This table does not calculate landed cost. The importer must also determine customs value under 19 U.S.C. 1401a, including assists, packing, royalties/license fees, proceeds and related-party acceptability. A “first sale” claim requires a bona fide sale for export to the United States, arm's-length evidence and a complete transaction trail.
5. AD/CVD and evasion review
Do not infer trade-remedy status from the HTS number alone. Screen the country of origin, producer and written scope of every active AD/CVD order, and test any applicable Chapter 99 provision as of the entry date.
The written scope description is dispositive; an HTSUS number in an order is only a convenience reference. If coverage is uncertain, obtain a Commerce scope ruling under 19 CFR 351.225 before relying on a non-covered position. Minor processing or assembly in a third country can trigger a circumvention analysis. False origin, undervaluation or evasion can lead to EAPA investigation under 19 U.S.C. 1517 and civil penalties under 19 U.S.C. 1592.
6. Partner Government Agency and product compliance
Household hand-supported hair dryers without integral immersion protection can be a substantial product hazard under 16 CFR 1120.3(a). Confirm the applicable consumer-product certificate, test records, labeling, section 15 reporting obligations and mandatory CPSC certificate eFiling for covered imports on or after July 8, 2026.
PGA admissibility is independent of tariff classification. Transmit all required agency data and documents through ACE; a CBP release does not cure a violation of an FDA, CPSC, EPA, FCC, DOT, USDA or other agency rule.
7. Origin, marking and UFLPA
Determine nonpreferential origin under the substantial-transformation test and any product-specific rule; do not rely only on the shipping country, invoice origin or location of final packing. Mark the article and, when required, its container under 19 U.S.C. 1304 and 19 CFR Part 134, unless a documented exception applies. Section 301, AD/CVD, government procurement and a preference program may use distinct origin rules.
Under 19 U.S.C. 1307 and the UFLPA, goods mined, produced or manufactured wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List, are subject to a rebuttable presumption of exclusion. Maintain supplier identity, production, payment, logistics and input-tracing evidence; a generic supplier declaration is not enough for a high-risk supply chain.
8. Minimum entry file
- CBP entry/cargo release data and Form 7501 record, customs bond, commercial invoice, packing list and bill of lading/air waybill.
- Purchase orders, payment records, Incoterms, assists/royalties analysis and related-party or first-sale valuation support.
- Product specifications, drawings, photographs, manuals, composition/BOM, model cross-reference and condition as imported.
- Signed classification memorandum applying the GRIs, legal notes, current HTSUS text and relevant rulings, plus rejected alternatives.
- Origin and marking analysis; producer/supplier affidavits and traceability records; Chapter 99 and exclusion support.
- AD/CVD scope search, producer/exporter case numbers and cash-deposit instructions, even when the conclusion is “not covered.”
- All PGA registrations, certificates, laboratory reports, licenses, notices and ACE data required for this product.
Keep entry and supporting records for the statutory period, generally five years, under 19 U.S.C. 1508 and 19 CFR Part 163.
9. Principal legal risks
- Declaring a 10-digit number from the trade name without proving the imported condition and legally relevant characteristics.
- Omitting a Chapter 99 number or calculating only the Column 1 rate.
- Treating an AD/CVD HTS cross-reference as dispositive instead of reading the written scope.
- Using shipping country as origin without a substantial-transformation and marking analysis.
- Filing before PGA admissibility, certificates, laboratory evidence or supply-chain traceability are complete.
An incorrect entry can produce redelivery, exclusion/seizure, duty reassessment, interest, loss of liquidation defenses and penalties. If past entries contain a material error, promptly evaluate a post-summary correction, protest, prior disclosure under 19 CFR 162.74 or other corrective procedure with U.S. customs counsel; the correct route depends on entry and liquidation status.
10. Pre-entry action checklist
1. Lock the specifications and imported configuration for the exact SKU. 2. Re-run classification against the current HTSUS and record GRI/Note reasoning. 3. Determine customs value, nonpreferential origin and marking. 4. Screen Chapter 99, Section 301/232, quota/safeguard and every potentially relevant AD/CVD scope. 5. Complete the product-specific PGA review and obtain supporting certificates before shipment. 6. Calculate landed duties and fees, then have the importer and licensed customs broker validate ACE reporting. 7. For unresolved or commercially material classification issues, obtain a CBP Part 177 ruling before importation.
Official legal sources
- United States International Trade Commission; HTSUS 2026: Harmonized Tariff Schedule of the United States
- U.S. Customs and Border Protection; HQ 959906: Electrothermic hair dryer classification analysis
- Consumer Product Safety Commission; 16 CFR 1120.3(a): Hand-supported hair dryers
- USITC — Current Harmonized Tariff Schedule of the United States
- CBP — User fee table: MPF rate and FY 2026 minimum/maximum
- CBP — Harbor Maintenance Fee
- CBP — ACE: filing customs and Partner Government Agency data
- USTR — Section 301 tariff actions and exclusion search
- BIS — Section 232 steel and aluminum measures
- Commerce — AD/CVD FAQs, scope and circumvention rules
- Commerce — ACCESS AD/CVD proceeding search
- CBP — UFLPA rebuttable presumption
- CPSC — Certificates and mandatory eFiling guidance
- FDA — Importing food products into the United States
- EPA — TSCA requirements for importing chemicals
- PHMSA — Lithium battery transportation requirements
- FCC — Equipment authorization
- eCFR — 19 CFR Part 177: administrative rulings
- eCFR — 19 CFR Part 134: country-of-origin marking
- eCFR — 19 CFR Part 163: recordkeeping
> Legal notice: This article provides general U.S. customs and trade-compliance information based on the stated facts as of September 5, 2026. It is not a CBP, Commerce or PGA ruling and is not legal advice for a specific transaction. Current HTSUS/Chapter 99 text, agency requirements and case-specific AD/CVD instructions must be rechecked at entry.
Editorial note
Prepared by the Global HS Code Checker Editorial Team for customs-classification, tariff and import-policy research. The correct code and applicable measures may change with the merchandise's actual characteristics, jurisdiction, entry date and supporting record. Verify the current tariff, governing measures and competent customs authority before filing an entry. A reviewer is identified only after a named expert has completed the review.
